Director Perspective-Toward Smarter Accountability: Reimagining the CFSR

By Rebecca Jones Gaston, former Commissioner of the U.S. Administration on Children, Youth and Families in the Department of Health and Human Services 

Read it here as a downloadable and printable PDF.

For more than 25 years, the Child and Family Services Review, or CFSR, has been the primary federal mechanism for assessing state child welfare system performance. 

Its purpose is well-intended; to ensure that children are safe, supported to achieve permanency, and able to experience well-being. The results leave more to be desired. 

A recent ASPE analysis confirms a striking reality; no state has ever passed a CFSR across multiple rounds of review. 

This finding should not be interpreted as evidence of collective failure by states. 

Instead, it signals that our accountability metrics and policies are themselves not aligned with the complexity and evolution of child welfare systems. 

The process becomes the work instead of the outcomes and well-being of children and families.

I have experienced the CFSR from multiple vantage points. 

As a state child welfare director in Oregon and Maryland, I was responsible for leading agencies through reviews and Program Improvement Plans. 

Later, in federal government, I oversaw child welfare policy and accountability. From those perspectives, the ASPE finding is not surprising. 

When these distinct forms of accountability are collapsed into a single determination of substantial conformity, states can follow the law, spend funds appropriately, and still be labeled as failing. 

Under those conditions, it is not surprising that no state has ever passed.

It is, however, deeply instructive, and calls us to move beyond critique and toward a clearer vision of what accountability in child welfare should be.

Toward A New Accountability 

A smarter accountability system would reflect the realities of modern child welfare: outcomes shaped across systems, success that often appears as non-events, and improvement that depends as much on capacity and coordination as on compliance. 

Additionally, accountability has to span through the entire process to include calls to the hotline and all of the decision points and factors that determine whether further involvement occurs.

Accountable to Who? Outcomes Shared Across Systems

Child welfare outcomes do not sit with one agency alone, yet that agency bears the risk of not meeting them. 

Safety, permanency, and well-being are shaped by decisions and services across courts, legal representation, law enforcement, behavioral health, education, housing, income supports, and community-based organizations. 

Yet the CFSR largely evaluates success based only on what falls within the administrative control of a single agency.

When outcomes fall short, accountability lands disproportionately on child welfare agencies.

The levers for improvement are distributed across systems with different governance structures, funding streams, and incentives. But we haven’t modernized our accountability framework to reflect that reality.

Targeting Accountability 

A smarter accountability framework would recognize that outcomes are shared and co-produced, and would assess how systems work together rather than how one agency performs in isolation. 

Under a smarter accountability framework, a state’s permanency outcomes would be assessed alongside court timelines, access to legal representation, and behavioral health capacity, making clear which results reflect agency practice and which reflect cross-system constraints.

Rewarding Integration, Prevention, and Cross-Sector Collaboration

The child welfare field has evolved significantly over the past decades. 

States are increasingly investing in prevention services, family preservation, kinship supports, lived-experience partnerships, and cross-system strategies aligned with Family First and broader prevention efforts. 

Success in these areas often shows up as absence: children who never enter foster care,families stabilized before crisis, and communities equipped to respond earlier.

The CFSR has struggled to fully capture these shifts. 

When prevention and integration are not meaningfully recognized, accountability frameworks unintentionally reinforce a foster-care-centric definition of performance. 

Incentivizing Accountability

A smarter accountability framework would reward systems for working across sectors and upstream to support families before harm occurs.

A smarter accountability system would credit reductions in foster care entries and shorter system involvement as performance signals, even when those successes occur outside the foster care system itself.

Aligning Federal Reporting Into a Coherent Whole

In theory, the CFSR should function as an integrated accountability ecosystem. 

In practice, they often fragment attention and drive reactive compliance. 

Leaders and staff focus on the requirement immediately in front of them rather than on how these tools collectively support long-term strategy and system transformation.

Over time, process can become the work itself, and outcomes suffer. 

Making Accountability Coherent

Accountability should reinforce coherence, learning, and strategic alignment, not compete for limited leadership attention and workforce capacity.

Rather than treating plans, reviews, and improvement processes as separate exercises, smarter accountability would read them together — evaluating whether a jurisdiction’s strategy, investments, and results are coherently aligned over time.

Distinguishing Compliance from Performance

An additional challenge embedded in the CFSR framework is the blurring of two distinct forms of accountability: compliance with federal policy and fiscal requirements, and accountability for performance outcomes.

Both matter–but they serve different purposes. 

States must follow federal law and steward public funds responsibly. These expectations are necessary and appropriate. 

But performance outcomes such as safety, permanency, and well-being are shaped by factors that extend far beyond policy adherence and spending decisions alone. 

Workforce stability, court practices, service availability, community capacity, and broader social and economic conditions all play critical roles.

When compliance and outcomes are collapsed into a single determination of substantial conformity, states can meet legal and fiscal requirements while still being labeled as failing. 

Shifting Accountability from Compliance to Performance

A smarter accountability system would treat compliance as a baseline expectation, while assessing performance through a more developmental lens that recognizes relative progress over time, and contextual challenges.

In practice, this would mean treating statutory and fiscal compliance as a threshold requirement, while evaluating performance through trend data, improvement trajectories, and contextual factors that influence outcomes.

Balancing Accountability with Capacity Building and Investment

Identifying gaps without ensuring the capacity to address them creates cycles of perpetual remediation. 

Workforce shortages, service gaps, and uneven community infrastructure cannot be solved through oversight alone. 

States are expected to improve outcomes while navigating constrained budgets, high turnover, and increasing complexity in family needs.

Capacity for Accountability

Smarter accountability would pair expectations with meaningful capacity-building support, including targeted federal investment, technical assistance, and flexibility tied to evidence-informed strategies. 

Accountability without capacity does not drive improvement. It drives compliance.

Centering Child and Family Experience As a Core Indicator of Quality

Some of the most important outcomes in child welfare remain difficult to measure but impossible to ignore. 

Whether families feel respected and heard. Whether children experience belonging and stable relationships. Whether services are timely, culturally responsive, and address root causes. Whether inequities are reduced over time.

The CFSR has made progress in its processes by incorporating greater community and partner voice, but these perspectives often remain secondary to traditional compliance findings. 

Family-Focused Accountability

A smarter accountability system would treat child and family experience not as supplemental context, but as a core indicator of system quality. 

Feedback from youth and families about respect, stability, and access would weigh alongside process measures in determining system quality, rather than functioning as supplemental context.

Moving Forward

The fact that no state has ever passed a CFSR is not a verdict on state effort or commitment. Fiscal penalties have also not impacted sustainable improvements either. It is a call to modernize how we define, measure, and support quality in child welfare. 

CCWIS has been riddled with complications, protracted procurements and large price tags.  

Data and information are essential to understanding what is happening in practice. Accountability cannot be driven by fear based, punitive tactics at federal, state, and local levels. There is a need for something different.

The goal of child welfare should never be compliance for its own sake. 

It should be creating conditions in which children are safe, families are supported, and communities have the resources to thrive. If our accountability tools are not fully advancing that goal, then reimagining them is not optional. It is essential.